OFFICE OF

MMAA

DDEEM

F THE SP

DDEEPPAA

AANNAAGGE

OOFF

IINNTTE

IINN

EMMOOCCR

PECIAL I

AARRTTMM

GEEMMEENN

FF CCOOSS

EERRNNAA

NNSSTTIITTUU

RRAATTIICC

INSPECTO

MMEENNTT

NNTT:: LL

SSTTSS AA

AATTIIOONN

UUTTEE AA

CC IINNSS

GGRR

OR GENE

OOFF SS

LLIIMMIITT

AANNDD IIM

NNAALL RR

AANNDD NN

STTIITTUUTT

RRAANNTTSS

ERAL FOR

STTAATTEE

TTEEDD OO

MMPPAACC

RREEPPUUBB

NNAATTIIOO

TTEE DD

SS

R IRAQ R

EE GGRRAA

OOVVEERRS

CCTT OOFF

BBLLIICCAA

OONNAALL

EEMMOOCC

SSIIGGI

JJJAAANNNUUUAAARRR

RECONST

AANNTT

RSSIIGGHHT

FF

AANN

LL

CCRRAACC

GIIRR1100--00

RRRYYY 222666,,,222000

TRUCTIO

HTT

CCYY

001122

000111000

ON
SIGIR 

Special Inspector General for IRAQ Reconstruction 

For more information, contact SIGIR Public Affairs at 

(703) 428-1100 or PublicAffairs@sigir.mil Special Inspector General for Iraq Reconstruction 

Summary of Report: SIGIR 10-012 

Why SIGIR Did this Study 

This report addresses the Department of State’s 

Bureau of Democracy, Human Rights, and 

Labor’s (DRL) management of 12 grants issued 

between 2004 and 2009, valued at 

approximately $248 million, to the International 

Republican Institute (IRI) and the National 

Democratic Institute (NDI) for democracybuilding activities in Iraq. SIGIR’s reporting 

objective is to examine the Department of 

State’s oversight of the costs and outcomes of 

IRI and NDI democracy-building grants in Iraq. 

What SIGIR Recommends 

SIGIR recommends that the U.S. Secretary of 

State improve DRL oversight of grants by 

directing DRL to (1) review and document the 

reasonableness of grantee budgets for activities 

not directly associated with executing grant 

objectives, to include security and other indirect 

costs, and the costs versus benefits of awarding 

grants with significant non-direct program costs; 

(2) request for current grants and require for 

future grants that grantees report quarterly 

expenditures on major cost categories; and 

(3) assess the appropriateness of establishing a 

program manager position in Iraq versus 

maintaining democracy advisors as DRL 

representatives in Iraq. 

SIGIR also recommends that the Deputy 

Secretary of State for Management and 

Resources direct an examination of DRL’s 

personnel and operations to determine if the 

Bureau is structured and staffed to effectively 

and efficiently oversee the grants under its 

responsibility. 

Management Comments and Audit 

Response 

DRL concurred with three of the draft report 

recommendations but did not concur with a draft 

recommendation that it amend grant agreements 

to require grantees to report quarterly 

expenditures on major cost categories. DRL 

stated that formal amendments to current grants, 

as well as expired grants, may not be useful, but 

it will request this of grantees receiving future 

grants. SIGIR modified its final report 

recommendation related to cost category 

reporting to reflect the DRL comment. 

January 26, 2010 

DEPARTMENT OF STATE GRANT MANAGEMENT: LIMITED 

OVERSIGHT OF COSTS AND IMPACT OF INTERNATIONAL 

REPUBLICAN INSTITUTE AND NATIONAL DEMOCRATIC INSTITUTE 

DEMOCRACY GRANTS

What SIGIR Found 

DRL does not have documentation on whether the IRI and NDI grants are 

meeting their goals and whether the grant money is being used in the most 

effective and efficient manner. While IRI and NDI stated they have assessed 

the impact their grants have had in achieving grant objectives, DRL has not 

required that IRI and NDI provide these assessments in progress reports, as 

required by the grant agreements. A DRL program official stated that DRL 

recently hired a specialist to improve the evaluation process and determine 

methods to measure impact of the grants. 

During our review of the costs for seven grants, we found that only 41% of 

the grant funds were actually spent on direct program activities. More than 

60% of IRI’s expenditures and almost 50% of NDI’s expenditures were for 

security and overhead costs; mostly security. NDI spent almost one third of 

its funds on security, and IRI spent more than one half of its funds on 

security. Thus, only approximately $47 million of the approximately 

$114 million was spent on direct program activities. SIGIR notes that the 

level of security expenditures for a grant is a case-by-case decision and 

should be based on a cost and benefits analysis. Absent such an analysis, 

there is no basis to assess the appropriateness of security costs. 

Current DRL officials could not explain why the apparent risks associated 

with these grants, as evidenced by the significant security costs, were 

accepted because they were not assigned to manage these grants until after 

they had been awarded. They noted, however, that DRL received direction 

from Congress to ensure grant activities occurred. Nevertheless, the officials 

explained that DRL does not have a set formula to gauge an appropriate 

level for security costs per grant, and shifting circumstances may dictate 

security requirements. 

SIGIR also found that DRL’s oversight of IRI and NDI grants is limited. 

First, DRL manages the grant program from Washington, D.C. which limits 

face-to-face interaction with grantee personnel in Iraq and impacts insight 

into grantee activities. Second, DRL does not require that progress reports 

follow guidelines established by DRL in grant agreements. For example, 

grantees are encouraged to submit progress reports that identify the level and 

type of activities conducted for the period along with supporting 

documentation to provide evidence that activities occurred. NDI included 

supporting documentation in 22 of the 23 reports it submitted; IRI included 

supporting documents for only 3 of the 29 reports it submitted. Moreover, 

progress reports did not provide expenditure data by objective, as suggested 

in the grant. IRI and NDI submitted quarterly financial reports identifying 

total expenditures, but the reports do not break down expenditures into 

categories such as security or training. While relevant guidance does not 

require such detailed data, the information would benefit DRL’s oversight of 

the program. 
SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION 

400 Army Navy Drive • Arlington, Virginia 22202 

January 26, 2010 

MEMORANDUM FOR U.S. SECRETARY OF STATE 

U.S. AMBASSADOR TO IRAQ 

SUBJECT: Department of State Grant Management: Limited Oversight of Costs and Impact 

of International Republican Institute and National Democratic Institute 

Democracy Grants (SIGIR 10-012) 

We are providing this audit report for your information and use. The report discusses the U.S. 

Department of State’s Bureau of Democracy, Human Rights, and Labor (DRL) grants awarded 

to the International Republican Institute and the National Democratic Institute for democracybuilding activities in Iraq. We performed this audit in accordance with our statutory 

responsibilities contained in Public Law 108-106, as amended, which also incorporates the duties 

and responsibilities of inspectors general under the Inspector General Act of 1978. This law 

provides for independent and objective audits of programs and operations funded with amounts 

appropriated or otherwise made available for the reconstruction of Iraq, and for 

recommendations on related policies designed to promote economy, efficiency and effectiveness 

and to prevent and detect waste, fraud, and abuse. This audit was conducted as SIGIR project 

9024. 

We considered written comments from the Assistant Secretary, DRL, when preparing this report. 

The comments are addressed in the report where applicable, and the letter is included in 

Appendix F. 

We appreciate the courtesies extended to the SIGIR staff. For additional information on the 

audit report, please contact David Warren, Assistant Inspector General for Audits, (703) 604-

0982/ david.warren@sigir.mil, or Glenn Furbish, Principal Deputy Assistant Inspector General 

for Audits, (703)-604-1388/ glenn.furbish@sigir.mil. 

Stuart W. Bowen, Jr. 

Inspector General 

cc: U.S. Secretary of Defense 

Commander, U.S. Central Command 

Commanding General, U.S. Forces-Iraq 

Administrator, U.S. Agency for International Development 
Table of Contents 

Introduction 1

Background 1

Objectives 4

Impact of IRI and NDI Grants Not Documented and Most Grant Money 

Funds Security and Other Indirect Costs 5

DRL Has Not Required that IRI and NDI Demonstrate Impact of Their Democracy 

Efforts 5

IRI and NDI Grants Have Significant Security and Indirect Program Costs 8

DRL Oversight of IRI and NDI Grants Can Be Improved 13

DRL Does Not Have Program Managers in Iraq To Oversee Grants 13

DRL Records Are Incomplete 15

Conclusions and Recommendations 18

Conclusions 18

Recommendations 18

Management Comments and Audit Response 19

Appendix A—Scope and Methodology 21

Appendix B—NDI and IRI Expenditures for Selected Grants 24

Appendix C—IRI and NDI Recent Grant Activity Cited in Progress Reports27

Appendix D—Acronyms 33

Appendix E—Audit Team Members 34

Appendix F—Department of State – Bureau of Democracy, Human Rights, 

and Labor Comments 35

Appendix G—SIGIR Mission and Contact Information 37
1 

Department of State Grant Management: Limited 

Oversight of Costs and Impact of International 

Republican Institute and National Democratic Institute 

Democracy Grants 

SIGIR 10-012 January 26, 2010

Introduction 

On October 22, 2008, the Special Inspector General for Iraq Reconstruction (SIGIR) issued a 

report1 on the U.S. Department of State’s (DoS) and the U.S. Agency for International 

Development’s (USAID) strategy for democracy-building in Iraq. This follow-up report focuses 

on DoS’ Bureau of Democracy, Human Rights, and Labor (DRL) management of grants of 

approximately $248 million to the International Republican Institute (IRI) and to the National 

Democratic Institute (NDI) for democracy-building activities in Iraq. IRI is a nonprofit, 

nonpartisan organization with a stated mission to advance freedom and democracy worldwide by 

developing political parties, civic institutions, open elections, good governance and the rule of 

law. NDI is also a nonprofit, nonpartisan organization with similar goals; NDI’s stated goal is to 

work to support and strengthen democratic institutions worldwide through citizens’ participation, 

openness, and accountability in government. NDI’s mission in Iraq is to provide assistance and 

opportunities for participation to all Iraqis through programming focused on empowering civil 

society, strengthening political parties, developing better governance practices, encouraging the 

political participation of women and youths, and helping to ensure open and fair electoral 

processes. Both organizations report that they have been working in Iraq since 2003 to help 

promote the growth of democracy. Both IRI and NDI’s operations in Iraq are headquartered in 

Erbil; IRI has local national staff and NDI has U.S. staff in Baghdad. 

DRL’s mission is to lead U.S. efforts to promote democracy, protect human rights and 

international religious freedom, and advance labor rights globally. The grant officer, who is an 

employee of the Department of State Office of Acquisitions Management, appoints a grant 

officer representative (GOR), who is a DRL employee and has primary responsibility for grant 

management. The GOR ensures that the grantee is making adequate progress in achieving the 

project goals and objectives and that the funds are being used responsibly. As of September 14, 

2009, DRL was managing 44 democracy-building and governance-related grants in Iraq totaling 

approximately $275 million. At that time, ongoing grants of approximately $153 million, or 

about 56% of the total, were awarded to IRI and NDI. 

Background 

DoS awarded grants to NDI and IRI to conduct democracy-building activities in Iraq. Grants 

differ from contracts in purpose and level of anticipated government involvement. According to 

the Office of Management and Budget, contracts are to be used when the government intends to 

 

1 Opportunities to Enhance U.S. Democracy-Building Strategy for Iraq (SIGIR-09-001, 10/22/2008) 
2 

acquire property or services for the direct benefit or use of the Federal Government; grants may 

or may not directly benefit the government.2

 According to the DoS Foreign Affairs Handbook,3

grants are an assistance instrument that may be used when it is anticipated that the agency and 

the recipient will have no substantial involvement during performance of the grant, and the 

principal purpose is the transfer of money, property, or services to accomplish a public purpose 

of support or stimulation authorized by Federal statute. Nevertheless, DoS’ standard operating 

procedure for grant management states that the Department has a fiduciary responsibility to 

monitor the funds it allocates and administers. 

DRL Awarded Grants to IRI and NDI 

Between August 2004 and June 2009, DRL awarded six grants to IRI for approximately $113.7 

million and six grants to NDI for approximately $134.5 million. Tables 1 and 2 display the DRL 

democracy-building grants awarded to IRI and NDI.4 These grants include a $50 million IRI 

grant to increase the capacity of the Iraqi legislature’s Research Directorate to produce objective 

research reports concerning Iraqi legislation and a $700,000 NDI grant to strengthen Iraqi 

women’s capacity to participate effectively in the political process. To implement the grants, 

both organizations carry out activities such as training, conferences, and study visits to support 

development of political parties, women and youth outreach, and the use of media in political 

campaigns. 

 

2

 OMB Circular A-110, revised 11/19/1993, as further amended 9/30/1999, issued under the authority of 31 U.S.C. 

503 (the Chief Financial Officers Act), 31U.S.C. 1111, 41 U.S.C. 405 (the Office of Federal Procurement Policy 

Act), Reorganization Plan No. 2 of 1970, and E.O. 11541 ("Prescribing the Duties of the Office of Management and 

Budget and the Domestic Policy Council in the Executive Office of the President"). 

3

 DoS Foreign Affairs Handbook Volume 4, Handbook 3-Financial Management Procedures Handbook, revised 

9/06/2002. 

4

 The Iraq Relief and Reconstruction Fund, the Economic Support Fund and the Human Rights Democracy Fund 

have funded these grants. 
3 

Table 1—DRL Grants Awarded to IRI ($ in millions) 

Award 

Date Grant Number Project 

Grant 

Amount 

Expiration 

Date 

8/10/2004 S-LMAQM-04-GR-133a Political Organization Training $2.2 7/31/2008

6/12/2006 S-LMAQM-06-GR-097a 

Post-Elections Democratic 

Transitions 37.7 1/30/2008

9/12/2007 S-LMAQM-07-GR-209a 

Governance, Political Participation, 

and Civil Society 50.0 4/30/2010

5/12/2008 S-LMAQM-08-GR-549 Women’s Democracy Initiative 1.8 11/12/2009

8/4/2008 S-LMAQM-08-GR-601 

Pre-election Activities for Iraqi 

Provincial Elections 19.0 1/31/2010

6/11/2009 S-LMAQM-09-GR-560 

Election Assistance Program – 

Iraq 3.0 1/31/2010

Total $113.7 

Note: 

a Grants reviewed by SIGIR. 

Source: SIGIR analysis of DRL data, as of 8/31/2009. 

Table 2—DRL Grants Awarded to NDI ($ in millions) 

Award 

Date Grant Number Project 

Grant 

Amount 

Expiration 

Date 

8/31/04 S-LMAQM-04-GR-140a Political Training $1.5 3/31/06 

6/13/06 S-LMAQM-06-GR-098 Governance Civil Society 53.0 12/31/07

8/31/06 S-LMAQM-06-GR-149a Political Training 0.7 11/30/07 

9/12/07 S-LMAQM-07-GR-210a 

Governance, Political Participation, 

and Civil Society 50.0 7/31/10 

5/12/08 S-LMAQM-08-GR-550 Women’s Political Participation 1.8 4/30/10 

8/18/08 S-LMAQM-08-GR-602a 

Iraq: Preparing Domestic Monitoring 

Organizations and Political Parties 27.5 1/31/10 

Total $134.5 

Note: 

a

 Grants reviewed by SIGIR 

Source: SIGIR analysis of DRL data, as of 8/31/2009. 

According to DRL senior officials, the grants were a mix of full and open competition and other 

than full and open competition awards. DRL explained that S-LMAQM-04-GR-133, 

S-LMAQM-04-GR-140, and S-LMAQM-06-GR-149 resulted from fully open competitions. 

Grants S-LMAQM-07-GR-209 and S-LMAQM-07-GR-210 were limited source, meaning letters 

were sent to a limited number of qualified organizations who had to submit proposals for funding 

that was not guaranteed. In addition, S-LMAQM-06-GR-097 consisted of two separate sole 

source solicitations stemming from Congressional funding for $10 million and $27 million, 
4 

which were combined into one grant. Finally, S-LMAQM-08-GR-602 consisted of a 

combination of an initial limited source negotiation for $2 million, a subsequent open 

competition award of $20 million, and a final limited source negotiation resulting in a 

$5.5 million addition. For detail on recent grant activities for these two grantees, see 

Appendix C. 

Objectives 

SIGIR’s reporting objective is to examine the Department of State’s oversight of the costs and 

outcomes of IRI and NDI democracy-building grants in Iraq. . 

For a discussion of the audit scope and methodology, see Appendix A. For information on IRI 

and NDI expenditures for selected grants, see Appendix B. For information on IRI and NDI 

recent grant activity cited in progress reports, see Appendix C. For a list of acronyms used in 

this report, see Appendix D. For a list of the audit team members, see Appendix E. For a copy 

of Department of State – Bureau of Democracy, Human Rights, and Labor comments, see 

Appendix F. For the SIGIR mission and contact information, see Appendix G. 
5 

Impact of IRI and NDI Grants Not Documented and 

Most Grant Money Funds Security and Other Indirect 

Costs 

DRL does not have documentation on how well IRI and NDI grants are meeting their goals and 

whether the grant money is being used in the most effective and efficient manner. While IRI and 

NDI stated they have assessed the impact their grants have had in achieving grant objectives, 

DRL has not required that IRI and NDI provide these assessments in progress reports, as 

required by the grant agreements. According to IRI and NDI officials, they receive feedback 

from grant participants on the impact of individual activities like trainings as well as larger 

overall impacts of the training provided within the community. According to a DRL official, 

DRL recently hired a specialist to improve the evaluation process and determine methods to 

measure impact of the grants. 

For the three IRI grants we reviewed, 57.2% was spent on security and 6.4% was spent on other 

indirect costs (which are negotiated by each organization and are binding on the entire 

government). For the four NDI grants, 32.7% was spent on security and 16.9% was spent on 

other indirect costs. Thus, only $47 million (41%) of the $114 million in grant funds that we 

reviewed supported direct grant activities. 

DRL officials could not explain why the risks associated with these grants were accepted 

because they were not assigned to manage these grants until after they had been awarded. They 

added that DRL received direction from the Congress to ensure that grant activities occurred. 

Moreover, they said that they do not have a set formula to gauge an appropriate level of funds 

spent for security per grant. 

DRL Has Not Required that IRI and NDI Demonstrate Impact of 

Their Democracy Efforts 

While IRI and NDI state that they assess the impact of their grant activities and submit quarterly 

progress reports, DRL has not required that the progress reports include assessments of the 

overall or incremental impact of their grants, as required by the grant agreements.5

 DRL invited 

IRI and NDI to submit proposals for grants supporting various democracy-building initiatives in 

Iraq. Each of the seven grant solicitations we reviewed stated that proposals would be judged, in 

part, on the grantee’s evaluation plans to assess impact. However, details regarding what DRL 

would consider a favorable plan differed. For example, solicitations for two grants (S-LMAQM04-GR-133 and S-LMAQM-04-GR-140) in 2004 stated that plans may include qualitative and/or 

quantitative evaluation methods and should address both project outputs and outcomes. The 

solicitation provides no other guidance for a favorable plan and did not define outputs or 

outcomes. Conversely, solicitations for two grants awarded in 2007 (S-LMAQM-07-GR-209, 

 

5

 Grant agreements stated grantee quarterly progress reports should reflect the grantee’s continued focus on 

measuring project impact on the overarching goals or problems the projects set out to address. Assessment of 

overall impact and/or incremental impact, as appropriate, should be included in each quarterly progress report. 
6 

and S-LMAQM-07-GR-210) contained more detailed descriptions of suggested criteria for 

evaluation plans, including a distinction of outputs versus outcomes. Specifically, the 

solicitations stated: 

“Programs should demonstrate the capacity for engaging in impact assessments and 

providing long and short-term goals with measurable outputs and outcomes. Output 

information is important to show the scope or size of project activities, but it cannot 

substitute for information about progress towards outcomes or the results achieved. 

Examples of outputs include the number of people trained or the number of seminars 

conducted. Outcomes, in contrast, represent specific results a project is intended to 

achieve and are usually measured as an extent of change. Findings on outputs and 

outcomes should both be reported, but the focus should be on outcomes. Projects that 

propose an independent evaluation with a clear plan are encouraged.”

IRI and NDI Assert That They Have Assessed Impact 

Despite the lack of evaluation information provided to DRL, both IRI and NDI officials stated 

that they do assess the outcome of their work. An IRI official stated that IRI receives feedback 

from participants on all training events and discusses with the responsible staff ways that 

participants have benefited from the training and whether the participants have used the training 

in the community. Additionally, IRI stated that its local coordinators, who are positioned 

throughout the country, follow up with surveys on the training and also provide follow-up 

training. The official also stated that IRI has established an Office of Monitoring and Evaluation 

specifically for the purpose of developing ways to improve its grant reporting process. 

An NDI official stated that it collects a large amount of data that would be difficult to include in 

quarterly reports. Regarding its evaluation efforts, the official explained that NDI conducts 

monthly opinion polls that address its democracy efforts, specifically on its $50 million award on 

Governance, Political Participation, and Civil Society. Additionally, the official stated that NDI 

is conducting 36 focus groups per year in each province for each of the four groups—political 

parties, civil society, women’s groups and youth groups—that are receiving its training. 

According to NDI, the organization is also purchasing the results of polls conducted by an 

international firm that gathers Iraqis’ opinions on Iraq’s political parties. Additionally, NDI 

officials said that their local coordinators conduct follow-up surveys and training, and monitor 

the extent to which their participants are seen in the media. 

Grantee Progress Reports Do Not Provide Impact Assessments 

DRL did not enforce grant terms requiring grantees to submit impact assessments in progress 

reports. Both the IRI and NDI grants require evaluation plans that describe how the grantee will 

measure output and outcomes of their activities. In addition, DRL grant agreements required that 

grantees include assessments of overall impact and/or incremental impact, as appropriate, in 

quarterly progress reports to DRL. SIGIR reviewed seven grant agreements and found that all 

contained evaluation plans, but neither IRI nor NDI provided impact assessments in the progress 

reports they submitted. In addition, while evaluation plans included specific measurements that 

would demonstrate impact, DRL did not require that progress reports include these 

measurements. For example, NDI’s $50 million grant S-LMAQM-07-GR-210 includes an 

evaluation plan and the following techniques that would be used to evaluate progress: 
7 

• Obtain evaluations and responses to questionnaires from participants and partners to gain 

direct feedback on program activities; 

• Consult with partners and donors to allow programs to continue to be flexible and 

responsive to the needs of participants, partners, and donors; and 

• Develop and use focus groups for research to gauge Iraqi citizens’ opinions and attitudes. 

None of NDI’s progress reports on the grant included this type of data. Similarly, NDI’s $1.5 

million grant S-LMAQM-04-GR-140 states that NDI will measure progress toward meeting an 

objective for gender sensitization advocacy through pre- and post-program questionnaires. 

However, NDI’s progress reports for the grant do not include any such data and the grant 

terminated in May 2006. 

IRI grants also include evaluation requirements, but again such information has not been 

provided to DRL. IRI’s approximately $38 million grant S-LMAQM-060GR-097, which 

focuses on establishing a more open and transparent government in Iraq, contains an evaluation 

plan that identifies the following objectives and indicators from which IRI would measure 

impact: 

• The level of interaction of Iraqi Council of Representatives members and staff with Iraqi 

and international media in accordance with the internationally observed rules; 

• The extent to which the Iraqi Council of Representatives establishes standards and 

operating procedures to interact with the media; 

• The ability of Iraqi citizens to communicate directly with the elected officials, and the 

extent to which Iraqi Council Representative members are reaching out to their 

constituents via public outreach mechanisms (offices, websites, etc.) 

In this case, the IRI grant does not include a methodology for IRI’s assessment of progress for 

each of the indicators. IRI quarterly progress reports discuss IRI activities in pursuit of the 

indicators, but IRI has no formal measurements or milestones for progress. 

DRL officials stated that the GORs review progress reports and other information to evaluate the 

extent to which grantees are meeting objectives and may request additional information or 

clarification from grantees. This information, however, is not documented in grant files. DRL 

officials acknowledged the problem and stated that they were taking efforts to improve the 

quality of their assessments. Specifically, DRL informed SIGIR that they recently hired a 

Program Evaluation Specialist whose function would be to improve the evaluation process and 

determine methods to measure the impact of grant programs and assess the overall impact of 

DRL’s work. 

U.S. and International Development Organizations May Provide Potentially Useful Tools for 

Assessing Outcome 

U.S. and international organizations may provide potentially useful tools for DRL to consider in 

future efforts to assess how well IRI and NDI grants are affecting the growth of democracy in 

Iraq. To illustrate, in 1998 USAID developed a handbook to enhance the ability of democracy 

and governance project managers to monitor progress in achieving planned results and use 
8 

performance information to guide program implementation.6 The handbook states that the 

promotion of democracy is a complex and dynamic process, but that performance monitoring is a 

necessary and integral part of good program management. The handbook includes a general 

process for developing a performance monitoring system, and provides specific measurable 

metrics to evaluate impact. 

The U.S. anti-corruption program in Iraq provides an example of a way to assess impact. In July 

2009, the U.S. Anti-Corruption Coordinator for U.S. assistance programs in Iraq proposed four 

metrics with baselines and targets for 2008-2011. These include an overall means of measuring 

Iraq’s progress—compliance with the United Nations Anticorruption Convention—plus three 

basic elements of anti corruption elements: accountability (existence of laws against corrupt 

practices), enforcement (sanctioning violations of laws), and transparency (public’s access to 

information regarding government’s actions). 

International organizations are also developing methods to assess the status of a representative 

democracy that may be useful in assessing program impact. For example, through country 

surveys and comparable statistical and economic data, the Organization for Economic Cooperation and Development (OECD), an international organization of 30 countries, including the 

United States, provides its member countries tools with which to analyze and monitor their 

economic, social and environmental policies. Moreover, the OECD, the United Nations, the 

European Commission, the World Bank, and the International Monetary Fund founded the 

Partnership in Statistics for Development in the 21st Century (PARIS21) in 1999. PARIS21’s 

goal is to develop a culture of evidence-based policy making and implementation that serves to 

provide governance and government effectiveness in reducing poverty. PARIS21 pursues this 

goal by encouraging and assisting low income countries to design, implement, and monitor a 

national strategy for the development of statistics and has developed a pilot project named 

Metagora that focuses on methods, tools and frameworks for measuring democracy, human 

rights and governance. 

IRI and NDI Grants Have Significant Security and Indirect 

Program Costs 

Of the $114 million in grant expenditures we reviewed, IRI and NDI spent approximately 

$67 million (or 59%) on security and other indirect costs.7

 Specifically, about 33% of NDI’s 

expenditures from the four grants we reviewed, and about 57% of IRI’s expenditures from the 

three grants SIGIR reviewed, were for security. When indirect program costs are added, almost 

50% of NDI’s expenditures and about 64% of IRI’s expenditures were for expenses other than 

direct program expenses. Significant security and indirect program costs reduced the amount of 

resources available to support DRL programs. SIGIR notes that the level of security 

expenditures for a grant is a case-by-case decision and should be based on a cost and benefits 

analysis. Absent such an analysis, there is no basis to assess the appropriateness of security 

costs. 

 

6 Handbook of Democracy and Governance Program Indicators, U.S. Agency for International Development, 

8/1998 

7

 The total funding for the seven selected grants is approximately $169.6 million, or 68.3%, of the total funding for 

all IRI and NDI grants. SIGIR identifies the selected grants in Appendix A. 
9 

SIGIR identified cost elements in the seven grants that are directly associated with the 

performance of the grants. These elements include: 

• Salaries and benefits of grant personnel performing work on the grant, 

• Expenses for office space and utilities, 

• Travel and per diem of staff and grant participants, 

• Workshops and conferences set up to support the mission of the grants, 

• Office supplies and equipment consumed in performing grant activities, 

• Communications and postage used by grant staff in performing grant activities, and 

• Sub-grants and contractual services to accomplish the grant mission. 

Conversely, SIGIR identified a variety of other costs associated with the cost of doing work in 

Iraq but not directly associated with performing its grant responsibilities. These costs include: 

• Security costs for both IRI and NDI facilities and their personnel and training 

participants, and 

• Indirect costs allocated by the grantee for support services such as human resources and 

financial management.8

While IRI and NDI budgets are not composed of exactly matching cost elements, their common 

underlying accounting systems and charts of accounts allowed us to analyze expenditures at a 

detailed level. Through this analysis of what each grant contained, we developed five major 

categories to compare both organizations’ original grant budgets and actual expenditures. 

Because some of the grants were completed before our review and other grants were still 

ongoing, we used two different periods for our evaluation. For grants that had been completed, 

we used the date of the last or final cost report. For grants that were still active during our 

review, we used June 30, 2009 data which was the most recent data available during the review. 

Figure 1 shows NDI and IRI budgeted and actual costs by the major cost elements for the seven 

grants that we reviewed. Detailed expenditure data provided by IRI and NDI for each of the 

seven grants reviewed is in Appendix B. 

 

8 Indirect costs are costs which cannot be directly identified with a single contract or grant. To the extent that 

indirect costs are reasonable, allowable and allocable they are a legitimate cost of doing business payable under a 

U.S. Government contract. Each organization negotiates its indirect cost rates with one government agency which 

has been assigned cognizance. Usually the cognizant government agency is that agency which has the largest dollar 

volume of contracts with the firm or organization. The resulting Negotiated Indirect Cost Rate Agreement is binding 

on the entire government.
10 

Figure 1—Originally Budgeted Costs (Percent) and Actual Expenditures in Seven 

Grants 

Note: 

Numbers may not add to 100% due to rounding. 

Source: SIGIR Analysis of Grant Agreements and Data (as of 9/30/2009) Provided by NDI and IRI. 

IRI Spends Over One-Half of Its Funds on Security Costs 

As shown in Figure 1, for the three IRI grants that SIGIR reviewed, the original IRI budget 

included 42.3% for security costs and 10.4% for indirect costs. Based on our analysis of the 

latest available cost data for these grants, IRI has spent 57.2% of its approximately $75 million 

for security and another 6.4% for indirect costs. As such, at least 63% of the money IRI spent 

for these grants was used for expenses other than direct program expenses. 

IRI officials noted that their security costs are significant because security is extremely important 

to them and they are willing to pay necessary costs. A senior IRI management official stated that 

IRI wanted security teams that had U.S. or British military training, and less expensive security 

contractors did not have teams with this training. Moreover, the IRI official noted that moving 

IRI headquarters to the safer area in Erbil in 2007 did not mean that their security costs would 

decrease. Rather, the official stated, the cost of a security contract is based on the number of 

security personnel and vehicles required, not on the security conditions at a specific location. 

Moreover, IRI stated that the extension of the time period for the grant increased the percentage 

of the grant spent on security costs. For example, DRL approved the extension of a $50 million 

grant to promote Governance, Political Participation, and Civil Society from March 31, 2009, to 

October 31, 2009. As a result, IRI reprogrammed a number of line items to account for the 

increased time the grant would be used. IRI reduced the travel budget by increasing the number 

of in-country training sessions versus out-of-country training sessions and increased security 

costs to account for the longer grant period and the plans to open an office in Baghdad’s 

International Zone. 
11 

NDI Spends Almost a Third of Its Funds on Security Costs 

For the four NDI grants we reviewed, NDI had originally budgeted 25.9% of the total funds for 

security and 13.4% for indirect costs. Based on our analysis of the latest available cost data for 

these grants, NDI spent 32.7% of its total expenditures of approximately $39.5 million for 

security and another 16.9% for indirect costs. As such, no less than 49% of the money NDI 

spent from these grants was used for expenses other than direct program expenses. 

A senior NDI official stated that moving NDI headquarters to Erbil in 2007 and closing offices in 

other areas of the country reduced some security costs but that the savings were somewhat offset 

by additional travel expenses to bring people to Erbil. However, this statement regarding savings 

in security costs is not supported by the expenditure information that we reviewed and 

summarized in Figure 1. 

Documentation Lacking on DRL Budget Analysis and Approval of Security Costs 

Current DRL officials could not provide documentation showing that DRL reviewed the 

reasonableness of IRI and NDI’s proposed security budgets, nor could DRL explain why the 

apparent risks associated with these grants, as evidenced by the significant security costs, were 

accepted. The officials stated that they were not present when DRL approved budgets for grants 

we reviewed. However, a senior DRL official stated DRL accepted the apparent risks associated 

with these grants because DRL was fulfilling congressional direction to provide programmatic 

support for the electoral process in Iraq. According to another senior DRL official, DRL has a 

vigorous grant evaluation process that it must follow in evaluating grant proposals, and that a 

grant with significant security costs would definitely have received a budget review. The 

officials noted that this process requires in-depth assessments of grant proposals and budgets and 

documentation of all discussions and decisions. However this documentation was not always in 

the grant files. DRL program management officials further stated they believe that congressional 

direction to initiate the democracy-building program determined the timeline for the grants 

because the grants supported time specific events such as elections.9

 The officials stated the 

security environment in Iraq was volatile when DRL awarded the grants, but DRL could not 

defer the program until security costs came down. 

DRL officials explained that they do not have a set formula from which to gauge an appropriate 

level of security costs per grant and that shifting circumstances may dictate security 

requirements. A senior DRL official stated that DRL assesses each grant and grantee 

individually based on a grantee’s in-country experience and the nature, scope, and location of 

grant activities. For example, the officials noted that some Iraqi staff working for 

nongovernment organizations often want to blend in with the population so they would likely 

want to have a smaller security footprint than would a U.S. or international nongovernment 

organization. A senior U.S. Embassy official said that budgeting 50% of a grant for security is 

excessive. Another senior Embassy official also stated that 30% would be considered 

 

9

 An example is the Conference Report for the fiscal year 2004 emergency supplemental appropriation, H.R. 108-

337, which states that the conference agreement includes language similar to the Senate bill providing $100 million 

for democracy-building activities in Iraq and that elections are essential to restoring Iraqi sovereignty. The 

Conference Report further endorses Senate report language on the use of funds. The Senate report, S. 108-160, 

states that sufficient funds should be provided to IRI and NDI for political party and other democracy-building 

activities. 
12 

appropriate. SIGIR previously reported that security costs for some capacity-building contracts 

and grants ranged from 24% to 53%.10 Both IRI and NDI’s budgets for security costs were 

within this range, with NDI’s budget on the low end; but IRI’s actual expenditures exceeded that 

range. 

We reviewed grant file documentation of DRL’s review of the largest IRI grant proposal, 

specifically for grant S-LMAQM-07-GR-209. We found references to DRL’s evaluation of 

budgeted administrative costs but found no discussion regarding budgeted security costs. 

Furthermore, DRL officials could not provide us any additional information regarding the budget 

review process for that the grant because they were not assigned to manage the grants until after 

they were awarded. Thus, we could not determine whether DRL had conducted any analyses of 

the proposed spending for security. 

A DRL official further explained in an e-mail to us why the organization had not conducted a 

review of security budgets. The e-mail noted that in August/September 2007, when NDI and 

IRI's $50 million grants were negotiated and awarded, the security situation in Iraq remained 

extremely volatile. As such, the unpredictable, unstable security environment made protecting 

grantee personnel a priority of the implementing organizations; made adequate security a precondition for IRI and NDI expatriate staff to conduct program activities and trainings; and 

complicated efforts to determine the amount implementing organizations should spend on 

security. Furthermore, DRL noted that the death of an NDI staff member in January 2007, when 

her convoy was ambushed in Baghdad, Iraq, underscored the need for extensive security to 

protect expatriate personnel and enable them to conduct crucial democracy-building activities in 

Iraq, despite the dangerous security environment. Given these factors, DRL concluded that it 

was very difficult for DRL to question proposed security costs by NDI and IRI to implement 

their $50 million grants. 

We understand that IRI and NDI must protect their respective staffs and that DRL is in the best 

position to determine whether its grants and their expected benefits warrant the risk. However, 

we found no DoS or DRL guidance on how grant managers are to factor security risks into their 

decision-making. Moreover, in our October 2008 report, we recommended that the Secretaries 

of Defense and State and the Administrator, USAID, direct that when program managers are 

making decisions to start new projects they consider the cost of security relative to these 

projects’ planned benefits before funding the projects.11 DoS did not, however, provide 

comments on the report or the recommendation. Without the type of analyses we previously 

recommended, DRL may approve unnecessarily significant security budgets. 

 

10 Agencies Need Improved Financial Reporting for Private Security Contractors, SIGIR 09-005, 10/30/2008. 11 SIGIR 09-005. 
13 

DRL Oversight of IRI and NDI Grants Can Be 

Improved 

DRL management and oversight of IRI and NDI grants is limited. First, DRL manages the grant 

program directly from its Washington, D.C. headquarters, which limits face-to-face interaction 

with grantee personnel in Iraq and impacts insight into grantee activities. Second, DRL did not 

require that progress reports follow guidelines established in its grants, including the guidelines 

to submit progress reports that identify the level and type of activities conducted for the period 

along with supporting documentation to provide evidence that activities occurred. NDI included 

supporting documentation in 22 of the 23 reports it submitted, but IRI included supporting 

documents for only 3 of the 29 reports it submitted. Moreover, quarterly NDI and IRI progress 

reports did not address expenditures, and their required financial reports included only overall 

expenditures by quarter and not expenditures by category such as security or training. 

DRL Does Not Have Program Managers in Iraq To Oversee Grants 

DRL personnel charged with managing the IRI and NDI grants are based in Washington, D.C. 

rather than Iraq, thereby limiting oversight of grant activities. The limited number of trips DRL 

personnel make to Iraq, coupled with incomplete trip reports limits the amount of information 

available to assess grantee performance. Moreover, although DRL has stationed two democracy 

advisors in the U.S. Embassy in Iraq to assist GORs in overseeing the grantees, the advisors 

serve as liaisons with the grantees and do not serve as program managers or have the same 

authority as the GORs. A democracy advisor stated that the Provincial Reconstruction Team in 

Erbil also provides additional oversight of grantee activities. However, this oversight is not 

documented in grant files and NDI officials stated that NDI coordinates with the Provincial 

Reconstruction Team in Erbil as appropriate, but there is no formal relationship with them in 

either a programmatic or management capacity. 

GORs Site Visits to Iraq Uncertain 

The DRL Iraq program consists of a seven-person team: five of the members are located in 

Washington D.C. and two democracy advisors, who are Foreign Service officers, are located in 

the U.S. Embassy in Baghdad. DRL’s standard operating procedure encourages GORs to make 

site visits as a means to monitor projects and requires that GORs submit standardized trip reports 

following visits. Site visits provide GORs opportunities to meet with grantee personnel, observe 

activities, review documentary evidence of activities, and provide feedback to grantees on 

progress or adjustments that could improve execution. GORs assigned to IRI and NDI grants are 

based in Washington, D.C. and, according to DRL officials, have conducted periodic site visits 

to Iraq. However, limited DRL staffing, travel cost considerations, security, and country 

clearance restrictions have impacted the frequency and length of site visits. 

According to a DRL official, DRL cannot identify how many site visits each GOR has made for 

grants assigned to them because trips are not made only to monitor grants. As such, while GORs 

and/or other DRL personnel travel to Iraq several times a year and trips may be up to 6 weeks 

long, site visits include meetings with multiple grantees, including grantees under the purview of 
14 

other GORs. Site visits may include visits to grantee performance locations and/or meetings 

with grantees in Baghdad. In addition, site visits made by personnel assigned to specific grants 

may differ from those by personnel not assigned to grants. For example, an IRI official told us 

GORs will review supporting documentation for activities during site visits, but other DRL 

officials will not. Without regular face-to-face interaction, GORs rely on e-mail and telephone 

calls to grantees for program monitoring and feedback. The DRL Manager of Global Programs 

stated that GORs communicate regularly with grantees in Washington, D.C., and that DRL’s 

democracy advisors in Baghdad are in contact with grantees on the ground in Iraq. GORs and 

democracy advisors discuss the status of grant activities with each other at least weekly. 

IRI and NDI relocated their Iraq operations headquarters from Baghdad to Erbil in 2007 after 

unidentified assailants ambushed a convoy and killed an NDI staff member returning from a 

training trip. An NDI senior official stated that NDI later learned it was the target of the attack. 

This event and other security threats prompted IRI and NDI’s boards to move their respective 

Iraq operations headquarters to Erbil where conditions were safer. As of October 2009, IRI and 

NDI continued to conduct most training and meeting events in Erbil, even though DRL officials 

state they have encouraged both grantees to relocate their headquarters in Baghdad. The 

relocation has impacted DRL’s oversight since the democracy advisors are located at the U.S. 

Embassy in Baghdad. Erbil is nearly 200 miles from Baghdad, and travel and billeting 

limitations affect the ability of the GORs and other DRL personnel to observe grantee activities 

there. However, GORs have visited the grantees’ offices and facilities in Erbil. Officials from 

both IRI and NDI stated that they plan to move more operations to Baghdad, but did not provide 

any specific plans to do so. 

Trip Reports Provide Limited Detail 

DRL policy requires GORs to submit trip reports to the program office within five days of 

returning from site visits. Previously, DRL required GORs to ask grantees detailed questions 

and provide in-depth responses. For example, the GOR was expected to ask the grantee what 

had been accomplished to date and whether the grantee had recommendations to improve the 

program. However, the DRL 2009 guidance contains fewer questions, and the remaining 

questions can often be answered with a yes or no response. For example, the new form asks if 

the project appears to be meeting goals, whether there are any deliverables from the project, and 

whether there are any funding or management issues. Detailed information on how the GOR 

arrived at the yes or no conclusion is not required. In addition, even with the reduction in 

requirements, trip reports do not always follow the prescribed format. In a review of a 

judgmental sample of five trip reports, SIGIR found notes from meetings and some insightful 

observations, but only one report formally adhered to the template developed by DRL. 

According to a DRL official, GOR observations on these broad questions are not made in haste 

and continued that it is up to the trained GOR to use his or her judgment to determine whether a 

program is on target by looking at grant agreements, grantee progress reports, and discussions 

with the grantee. However, as noted earlier, the grantee progress reports we reviewed contained 

little information on grant progress. 
15 

DRL Personnel in Iraq Lack Authority To Oversee Grants 

In June 2007, DRL established two democracy advisor positions at the U.S. Embassy in Baghdad 

to serve as DRL’s liaisons with the grantees, USAID, U.S. Embassy personnel, and Provincial 

Reconstruction Teams. According to a DRL official, the liaisons in Baghdad are responsible for 

approximately 50 DRL grants with approximately 22 grantees, at present. The advisors are to 

maintain close communication with IRI and NDI representatives through e-mails and telephone 

calls and through direct meetings when the representatives are in Baghdad. Additionally, the 

advisors sometimes travel to the grantees’ headquarters in Erbil. However, the advisors do not 

formally evaluate the grantee programs or have the same authority as the GORs involving grant 

activities. Rather, DRL considers them to be liaisons that can act as intermediaries and provide 

feedback to the GOR when requested. DRL program management officials believe the 

democracy advisors play an important role and that DRL does not need personnel with decisionmaking authority in Iraq because of the regular communication between the GOR and the 

advisors via e-mail or telephone. Moreover, an advisor said that the number of grants does not 

distract from his ability to monitor IRI and NDI activities. Rather, he noted that he focuses 

40-45% of his time on IRI and NDI because they receive the bulk of DRL’s grant funding in 

Iraq. The advisor added that the Provincial Reconstruction Team in Erbil also provides 

additional oversight of grantee activities. However, this oversight is not documented in grant 

files. 

DRL Records Are Incomplete 

Because DRL’s records are incomplete, it is unclear whether DRL properly assigned GORs and 

whether GORs have enforced grant agreement terms. Our review of IRI and NDI quarterly 

reports indicates that GORs have not required that IRI and NDI quarterly reports follow the 

format specified in grant awards, and GOR reviews are essentially rewrites of grantee reports. 

Moreover, DRL does not require comprehensive expenditure information by category, such as 

security or travel, or by grant objective to help DRL assess whether costs appear reasonable and 

on target with approved budgeted costs, and if funds support grant objectives. 

DRL Records of GOR Appointments Are Incomplete 

DRL does not have complete records to document whether oversight personnel for IRI and NDI 

grant management were properly assigned. Such documentation is important because the GOR 

has authority over the release of funds and the GOR has primary responsibility for oversight. 

For the seven grants that we reviewed, DRL was able to provide formal GOR appointment letters 

for only three individuals. Moreover, the dates of two of the appointment letters were in the 

middle of the grant performance period. According to a DRL official, the appointments were the 

result of turnover and assignment of a successor GOR. Another DRL official told us GOR 

appointment letters are maintained by the DoS Office of Acquisitions Management. The official 

said DRL requested the letters multiple times, but the Office of Acquisitions Management was 

not responsive. 

Quarterly Reports Do Not Follow Established Format and Lack Detail 

OMB guidance for grant administration states that grantees should submit performance reports at 

least annually, but not more frequently than quarterly. For each of the seven grants we reviewed, 
16 

DRL required in the grant award that grantees submit program progress reports and financial 

reports on a quarterly basis. DRL also suggested that reports be compiled according to the 

objectives of the projects and that for each objective/goals, reports include: 

• significant activities of the period and how activities reflect progress toward achieving 

objectives/goals; 

• evaluation of progress on objectives/goals with quantitative and qualitative data, as 

appropriate; 

• any problems/challenges in implementing the program and a corrective action plan; 

• an update of expenditures during the quarter; and 

• supporting documentation or products related to project activities (such as articles, 

meeting lists and agendas, manuals, etc.). 

DRL records contained 29 of 33 required quarterly reports from IRI and 23 of 25 from NDI. 

Five of the omitted reports were for the first reporting period of the grant. GORs generally 

excused this omission because the initial grant work includes start-up tasks that do not provide 

an opportunity for immediate reporting of impact, according to a DRL official. Although the 

grantees submitted progress reports for most periods, the reports did not provide all data and 

documentation encouraged by DRL in grant agreements. Specifically, reports did not always 

include supporting documentation and an update of expenditures for each objective. 

Supporting documents in quarterly progress reports provide evidence that activities occurred and 

progress is being made, but those documents are not always included with reports. NDI included 

supporting documents in 22 of the 23 reports submitted to DRL, but IRI included supporting 

documents for only 3 of the 29 reports it submitted. Moreover, while some reports include 

support like a table identifying grant activities with the associated numbers of participants by 

gender, governorate, and participating organization, others included only calendars of training 

dates during the period. IRI and NDI officials said that they maintain supporting documentation 

for all their activities but do not always include the documentation in quarterly reports because 

they see it as a burden for DRL. In addition, some supporting documentation, such as attendance 

sheets were not included in reports as a security measure to protect Iraqis participating in their 

programs. The grantee officials said that information is always available and is sometimes 

reviewed by GORs during site visits. However, as noted earlier in this report, GOR trip reports 

lack detail, thereby limiting the ability to confirm that GORs actually review these documents. 

Quarterly report narratives do not address expenditures during each quarter. According to a 

DRL official, Form 269 financial reports provided by IRI and NDI serve this function. DRL 

records contained 28 of 33 required quarterly reports from IRI and 23 of 25 from NDI. 

However, these Form 269 reports are overall summaries of total expenditures during the quarter. 

They do not show expenditure by objective, as encouraged by DRL in the grant awards. In 

addition, the reports do not show the expenditure of funds by cost type, or by the original 

approved budget categories such as security or indirect costs. According to a DRL official, the 

Form 269s provide a means of ensuring that the grantees are spending money at a reasonable rate 

and in accordance with the corresponding timeline of project work. If GORs see an unusual 

amount of money spent for reported work, they can seek an explanation, but the Form 269s alone 
17 

do not provide much detail. Without such information, DRL is unable to determine whether 

costs in a specific category, such as security, appear reasonable and on target with approved 

budgeted costs. While relevant guidance does not require such detailed data, the information 

would benefit DRL’s oversight of the program. 

A DRL official stated that even if grantees do not explicitly follow the suggested format, most 

adequately report significant activities of the period, evaluate how these activities reflect 

progress, and explain any challenges experienced during the period that contribute to hindering 

progress. 

GOR Feedback and Reviews of Progress Reports Have Not Effected Change 

Despite communication between GORs and grantees via telephone and e-mail, IRI and NDI 

officials told us that DRL has not provided feedback that their quarterly progress reports 

generally do not follow DRL’s suggested format. They said they may receive requests for 

clarification or additional detail on specific items in response to quarterly reports. According to 

a DRL official, GORs understand that they should judge progress on each objective based on the 

information provided in the report and follow-up where applicable. Follow-up or clarification is 

not required to be documented, however. 

DRL’s standard operating procedure requires that GORs read all quarterly reports and complete 

a GOR quarterly review. These reviews are to identify key accomplishments and challenges and 

to highlight success stories that can be shared within State, with Congress, or on State’s Website. 

GOR reviews of IRI and NDI quarterly reports are generally restatements of the quarterly reports 

and do not effectively measure impact. For the two largest grants, the GOR indicated it was 

pleased with IRI and NDI performance; however, our review indicates that the evaluations are 

generally rewrites of project information provided in the grantee progress reports and that the 

assessment of progress is limited due to the lack of quantitative data to measure the progress. 

 
18 

Conclusions and Recommendations 

Conclusions 

DRL has awarded IRI and NDI approximately $248 million in grants to promote democracy in 

Iraq. While the two grantees continue to execute and report grant activities, the indirect program 

costs and significant security costs, coupled with the lack of information on the impact these 

grants are having, raise questions about whether the costs of the grants are worth the benefits 

they may providing. Moreover, deficiencies in DoS oversight of the grants create additional risk 

that the grantees will not efficiently achieve grant goals, and that the funds will be vulnerable to 

fraud, waste and abuse. We recognize that efforts to promote democracy in Iraq are long term, 

and that assessing impact is not an easy task. This does not, however, relieve DoS from its 

fiduciary responsibility to ensure that U.S. assistance funds are being used in the most efficient 

and effective manner possible. 

Recommendations 

To improve DRL oversight of grants, we recommend the U.S. Secretary of State direct the 

Bureau of Democracy, Human Rights, and Labor take the following actions: 

1. Review and document the reasonableness of grantee budget costs for activities not directly 

associated with executing grant objectives, to include security and other indirect costs, and 

the costs versus the benefits of awarding grants with significant non-direct program costs; 

2. Request for current grants and require for future grants that grantees report quarterly on grant 

expenditures on major cost categories; and 

3. Assess the appropriateness of establishing a program manager position in Iraq versus 

maintaining democracy advisors as DRL representatives in Iraq. 

Because DRL’s grant management and oversight practices leave the Bureau vulnerable to fraud 

and waste, SIGIR recommends that the Deputy Secretary of State for Management and 

Resources direct: 

4. An examination of DRL’s personnel and operations to determine whether the Bureau of DRL 

is structured and staffed in both headquarters and overseas to effectively and efficiently 

oversee the grants under its responsibility. 

 
19 

Management Comments and Audit Response 

In written comments on a draft of this report, DRL generally agreed with the draft report 

recommendations. Specifically, DRL concurred with three and did not concur with one of the 

recommended actions. 

Concerning recommendation 1, DRL concurred with our recommendation that it review and 

document the reasonableness of budget costs for activities not directly associated with executing 

grant objectives, to include security and other indirect costs, and the costs versus benefits of 

awarding grants with high non-direct program costs. In its comments, DRL stated that it 

currently reviews the budgets of every proposal considered for funding and assesses each 

proposal’s cost effectiveness. DRL further stated they will modify grant review documents to 

ensure documentation of non-direct program cost levels and an associated cost-benefit analysis 

of awarding a proposal with federal funding. SIGIR notes that the level of security expenditures 

for a grant is a case-by-case decision and should be based on a cost and benefits analysis. 

Absent such an analysis, there is no basis to assess the appropriateness of security costs. As 

such, we modified our final recommendation to state that DRL’s review and documentation of 

the reasonableness of grantee budget costs should include an analysis of the costs versus the 

benefits of awarding grants with significant non-direct program costs. 

DRL also concurred with recommendation 2 that it assess the appropriateness of establishing a 

program manager position in Iraq versus maintaining democracy advisors as DRL representative 

in Iraq. DRL stated it plans to assess the appropriateness of creating such a position, in 

coordination with the U.S. Embassy, Baghdad. While DRL agreed with this recommendation, its 

response did not state when such an assessment would be conducted. Our review found that 

DRL’s current structure of program management personnel based in Washington, D.C. 

contributed to limited oversight of grantee activities and leave programs vulnerable to fraud, 

waste, and abuse. Therefore we encourage DRL to conduct this assessment quickly, but 

thoroughly to determine if program management personnel in Iraq would improve oversight. 

With regard to recommendation 4, DRL concurred with a recommendation that the Deputy 

Secretary of State for Management and Resources direct an examination of DRL’s personnel and 

operations to determine whether the Bureau of DRL is structured and staffed in both 

headquarters and overseas to effectively and efficiently oversee the grants under its 

responsibility. In its comments, DRL stated it will continue to examine its personnel and 

operations structure as part of an overall review of bureau staffing. SIGIR encourages DRL to 

communicate its findings with the office of the Deputy Secretary of State for Management and 

Resources. 

DRL did not concur with recommendation 3 that DRL amend grant agreements to require 

grantees to report quarterly grant expenditures on major cost categories. DRL agreed that 

receiving more detailed information on quarterly expenditures in major cost categories can 

provide an extra layer of oversight to help assess grant progress and prevent fraud and waste. 

However, DRL stated that formal amendments to current grants as well as expired grants may 

not be useful, but it will request this of grantees receiving future grants. We agree that amending 

grants nearing completion and expired grants may not yield significant improvements in 
20 

oversight. Nevertheless, such information could prove helpful in assessing future grant 

proposals. Based on the DRL comments, this final report recommends DRL request for current 

grants and require for future grants that grantees report quarterly on grant expenditures on major 

cost categories. 

DRL’s comments are reprinted in their entirety in Appendix F. DRL, NDI, and IRI provided 

oral and written technical comments, which we incorporated as appropriate. SIGIR believes that 

the actions identified by management, if properly implemented, are responsive to this report’s 

recommendations. 
21 

Appendix A—Scope and Methodology 

Scope and Methodology 

In June 2009, the Special Inspector General for Iraq Reconstruction (SIGIR) initiated 

Project 9024 to examine the Department of State Bureau of Democracy, Human Rights, and 

Labor’s (DRL) management of grants awarded to International Republican Institute (IRI) and the 

National Democratic Institute (NDI). SIGIR’s reporting objective is to examine the Department 

of State’s oversight of the costs and outcomes of the IRI and NDI democracy-building grants in 

Iraq. Since this report was sent out in draft for comment, we revised the title and reporting 

objective to more accurately reflect that the purpose of this audit was to examine Department of 

State management of these grants. The grants were issued between 2004 and 2009. 

We performed this audit under the authority of Public Law 108-106, as amended, which also 

incorporates the duties and responsibilities of inspectors general under the Inspector General Act 

of 1978. SIGIR conducted its work during June 2009 through January 2010 in Baghdad, Iraq 

and Arlington, Virginia. 

To determine the outcome and costs of the IRI and NDI grants, we first obtained and reviewed 

all grant documents and interviewed DRL, U.S. Agency for International Development, U.S. 

Embassy-Baghdad, IRI, and NDI personnel in Washington, D.C., and in Iraq. We obtained and 

reviewed budget, cost, and funding data from DRL, NDI, and IRI. We also analyzed changes to 

budgets and expenditures resulting from the awarding of no-cost extensions to grants. 

We selected a judgmental sample of seven IRI and NDI grants. The objective of our judgmental 

sample selection of the grants to review was to obtain a representative cross section for each 

grantee of open and closed grants and, to be somewhat consistent, the purpose and dollar 

amounts of the two in the event that we wanted to compare the results of the two grantees. We 

selected a $50 million open grant from each grantee. Then we selected recently closed grants, 

the grants to assist Iraqi women, one grant to IRI and two grants to NDI. The two NDI grants 

were two separate grants, but the second grant was made simply to continue the same assistance 

as that provided under the first grant. The other grant to IRI was given with a funded extension. 

We later selected two additional high-dollar grants for our sample, one from each grantee, 

because the seven grants would comprise a more representative sample of the entire universe of 

grants, based on total funding. 

For our review of the selected seven grants, we obtained and reviewed grant agreements, 

budgets, grantee quarterly progress reports, DRL grant officer representative (GOR) quarterly 

reviews, and grantee expenditures by cost type. The seven grants selected are: 

• S-LMAQM-07-GR-209 

• S-LMAQM-04-GR-133 

• S-LMAQM-06-GR-097 

• S-LMAQM-07-GR-210 

• S-LMAQM-08-GR-602 

• S-LMAQM-04-GR-140 
22 

• S-LMAQM-06-GR-149 

We also obtained and reviewed systems for gathering and reporting performance metrics, 

including the Handbook of Democracy and Governance Program Indicators, U.S. Agency for 

International Development, August, 1998, and the Partnership in Statistics for Development in 

the 21st Century. 

We also obtained and reviewed relevant criteria, including Office of Management and Budget 

Circular A-110, Office of Management and Budget Circular A-122, and Office of Management 

and Budget Circular A-133. In addition, we attended a meeting of the elections working group at 

the U.S. Embassy in Baghdad. 

To determine DRL’s management of the IRI and NDI grants, we interviewed DRL program 

management personnel in both Baghdad and Washington, DC. and democracy advisors in 

Baghdad. We obtained and reviewed documentation from the grant files and DRL’s Website, 

including: 

• documentation identifying the solicitation and grant award processes, 

• grant agreements and extensions for the grants selected in the sample, 

• grantees’ quarterly progress reports, 

• grantees’ financial reports (Form 269), 

• grant officer representative (GOR) reviews of the progress reports, 

• grantees’ documentation supporting grantee activities, and 

• GOR trip reports. 

We also obtained and reviewed DRL’s programming unit standard operating procedures. In 

addition, we visited IRI and NDI headquarters in Erbil, where we interviewed staff. 

We conducted the audit in accordance with generally accepted government auditing standards. 

Those standards require that SIGIR plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and conclusions based on our audit 

objectives. We believe that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

Use of Computer-processed Data 

We did use computer processed data in this report. DRL provided grant funding data in Excel 

spreadsheets. The Department of Health and Human Services’ Payment Management System 

originally processed the funding data. Both NDI and IRI use the Deltek accounting packaged 

software, and both stated that they had not modified the software. The budget and expenditure 

data we reviewed originated from their Deltek computer systems. We reviewed source 

documents and gathered other evidence to verify the data included in the accounting systems. 

We did not review these systems but consider the data sufficiently reliable for the purposes of the 

audit objectives. 
23 

Internal Controls 

We reviewed DRL internal control procedures to oversee and manage the grants. Specifically, 

SIGIR identified and assessed internal controls DRL used in evaluating and monitoring IRI and 

NDI grant proposals, activities and costs. 

Prior Coverage 

We reviewed the following reports by SIGIR and the U.S. Government Accountability Office: 

Special Inspector General for Iraq Reconstruction 

Agencies Need Improved Financial Reporting for Private Security Contractors, SIGIR 09-005, 

10/30/2008.

Opportunities to Enhance U.S. Democracy-Building-Strategy for Iraq, SIGIR 09-001, 

10/22/2008. 

Government Accountability Office 

Grants Management: Enhancing Performance Accountability Provisions Could Lead to Better 

Results, GAO-06-1046, 9/29/2006. 

Rebuilding Iraq: U.S. Assistance for January 2005 Elections, GAO-05-932R, 9/07/2005. 

 
24 

Appendix B—NDI and IRI Expenditures for Selected 

Grants 

We selected four NDI grants and three IRI grants for in-depth analyses of costs and activities. 

The following summarizes the NDI grant cost data reflected in Table 3: 

Grant: S-LMAQM-04-GR-140 “Iraq: Strengthening Women’s Political Participation” 

 Final Grant Period: September 1, 2004, to March 31, 2006 

 Final Grant Award Amount: $1,500,000 

 Cost Data as of: November 7, 2008 (Final) 

Grant: S-LMAQM-06-GR-149 “Iraq: Women’s Political Participation Program” 

 Final Grant Period: August 31, 2006, to November 30, 2007 

 Final Grant Award Amount: $700,000 

 Cost Data as of: February 29, 2008 (Interim) 

Grant: S-LMAQM-07-GR-210 “Iraq: Encouraging Constructive Political Dialogue and 

Participation” 

 Final Grant Period: September 12, 2007, to July 31, 2010 

 Final Grant Award Amount: $50,000,000 

 Cost Data as of: June 30, 2009 (Interim) 

Grant: S-LMAQM-08-GR-602 “Iraq: Preparing Domestic Monitoring Organizations and 

Political Parties for the 2008 Provincial Elections” 

 Final Grant Period: August 18, 2008, to January 31, 2010 

 Final Grant Award Amount: $27,500,000 

 Cost Data as of: June 30, 2009 (Interim)
25 

Table 3—NDI Grant Expenditures 

Expenditure 

S·LMAQM 

04·GR·140 

S·LMAQM

06·GR·149 

S·LMAQM

07·GR·210 

S·LMAQM 

08·GR·602 Total 

Salaries, Benefits 

and Allowances $ 420,108.86 $ 49,312.96 $ 

4,695,430.23 $ 258,509.86 $ 5,423,361.91

Office Space & 

Utilities 19,033.50 15,823.97 839,712.32 84,474.07 959,043.86

Supplies & 

Equipment 69,872.81 15,000.30 886,156.70 80,661.92 1,051,691.73

Communications 

& Postage 24,820.97 2,062.92 509,473.02 73,717.09 610,074.00

Travel & Per Diem 242,198.49 113,065.45 4,800,827.79 398,797.51 5,554,889.24 

Security 408,216.32 378,873.18 10,335,577.71 1,819,662.09 12,942,329.30 

Other Contractual 

Services 49,423.67 29,047.99 3,470,570.63 226,773.18 3,775,815.47 

Workshops and 

Conferences 42,812.84 34,767.18 492,449.93 42,776.00 612,805.95 

Other Direct Costs 5,828.71 686.92 882,733.33 83,697.70 972,946.66

Sub-grants 56,821.00 - 774,486.00 125,592.00 956,899.00

Indirect Cost 

Allocated 157,438.40 53,453.50 5,725,415.72 746,098.48 6,682,406.10

Total $1,496,575.57 $ 692,094.37 $33,412,833.38 $3,940,759.90 $39,542,263.22 

Source: NDI, as of September 30, 2009. 

The following summarizes the IRI grant cost data reflected in Table 4 

Grant: S-LMAQM-04-GR-133 “Women’s Leadership Institute”

 Final Grant Period: August 10, 2004, to July 31, 2008 

 Final Grant Award Amount: $2,200,000 

 Cost Data as of: December 31, 2008 (Final) 

Grant: S-LMAQM-06-GR-097 "Post-Elections Democratic Transitions” 

 Final Grant Period: June 12, 2006, to January 30, 2008 

 Final Grant Award Amount: $37,720,000 

 Cost Data as of: September 30, 2008 (Final) 

Grant: S-LMAQM-07-GR-209 “Iraqi Governance, Civil Society, and Political Party Programs” 

 Final Grant Period: September 12, 2007, to April 30, 2010 

 Final Grant Award Amount: $50,000,000 

 Cost Data as of: August 31, 2009 (Interim) 
26 

Table 4—IRI Grant Expenditures 

Expenditures 

S·LMAQM

04-GR-133 

S·LMAQM

07-GR-209

S·LMAQM 

06-GR-097 Total

Salaries, Benefits and 

Allowances $ 215,332.40 $2,074,255.18 $ 2,156,325.48 $ 4,445,913.06

Office Space & Utilities 150,114.14 1,087,307.34 1,199,478.61 2,436,900.09

Supplies & Equipment 123,376.72 479,110.49 760,029.68 1,362,516.89

Communications & 

Postage 46,668.66 497,805.14 591,880.52 1,136,354.32

Travel & Per Diem 177,663.48 3,336,541.96 2,864,457.24 6,376,662.68

Security 128,781.71 19,101,666.83 23,463,379.72 42,693,828.26 

Other Contractual 

Services 987,149.15 5,205,492.83 3,502,670.00 9,695,311.98

Workshops and 

Conferences 45,852.16 669,450.35 344,652.06 1,059,954.57

Other Direct Costs 5,272.13 111,105.95 136,594.11 252,972.19

Sub-grants - - 453,399.49 453,399.49

Indirect Cost Allocated 300,226.46 2,354,845.29 2,095,529.04 4,750,600.79

Total $2,180,437.01 $34,917,581.36 $37,568,395.95 $74,666,414.32

Source: IRI, as of September 30, 2009. 
27 

Appendix C—IRI and NDI Recent Grant Activity 

Cited in Progress Reports 

The following is information on grant activities that IRI and NDI included in progress reports 

they submitted to DRL. The information covers two ongoing grants: one $50 million IRI and 

one $50 million NDI grant, each of which is titled Governance, Political Participation, and Civil 

Society. We did not review this information for accuracy. 

IRI’s Grant Provides Training in Governance, Civil Society, and 

Political Parties 

IRI submitted seven quarterly progress reports on grant S-LMAQM-08-GR-209 covering the 

period October 1, 2007 through June 30, 2009. IRI’s progress reports identify the following 

objectives: 

Governance 

Foster transparency and commitment to public dialogue in the legislative process on the part of 

the new legislature and government. 

Objective: Enhance government capacity to perform core functions of national institutions. 

Objective: Foster transparency, public dialogue, and responsiveness in the legislative process. 

Civil Society 

Maintain Iraqi Civil Society Organization involvement in the political process and ensure that it 

continues to expand its base of participants throughout all regions of Iraq. 

Objective: Strengthen the organizational capacity, sustainability, and accountability of civil 

society to effectively engage in the democratic process. 

Objective: Encourage and facilitate dialogue among Iraqi civil society, Iraq local and national 

government, and international actors. 

Political Parties 

Objective: Encourage movement towards internally democratic, socially integrated, and issuesbased political organizations. 

Objective: Encourage movement towards internally democratic, socially integrated, and issuesbased political organizations. 

Objective: Facilitate the development of institutions, laws, and procedures that promote free and 

fair elections. 
28 

The following provides examples of the activity IRI reported in its progress report for the quarter 

ending June 30, 2009: 

Governance. IRI provides specialized training workshops to staff of the Iraq Council of 

Representatives Research Directorate. In April 2009, IRI trained eight new staff members of the 

Directorate’s legislative research department. The training focused on legislative writing and 

research support for Members of Parliament. IRI also sponsored a 5-day training session for the 

Directorate’s new budget department. In May and June, IRI supported the Directorate’s library 

by purchasing 396 volumes for the library’s collection. The volumes purchased included topics 

such as budget analysis, agricultural policy, and human rights. The library now owns 

approximately 8,000 volumes. 

During the quarter ending June 30, 2009, IRI expanded its public policy programs for think 

tanks. In May, the IRI-partner organization Iraqi Institute for Economic Reform conducted a 

seminar on the Iraqi banking industry. Numerous representatives from the government, the 

political community, and the banking community attended the seminar. IRI planned to sponsor 

six additional workshops in the following quarter. Planned topics include “Iraq’s Accession to 

the World Trade Organization” and “Aspiration for an Iraq Stock Exchange,” among others. 

Civil Society. During the quarter, four IRI-sponsored youth centers came together to host 29 

workshops in support of Campaign 25, an initiative promoting the idea of decreasing the 

candidacy age from 30 to 25 years of age. The four youth centers also used various paid and 

earned media platforms to promote Campaign 25. 

From April 19 to April 23, 2009 IRI’s Women’s Empowerment Program conducted two trainingof-trainers workshops for 41 participants in Baghdad. The workshops prepare participants to 

organize and host their own workshops in support of women’s rights. 

Political Parties and Research. On April 12-13, 2009 IRI held a coalition-building training that 

included 40 representatives from Kurdistan political parties. The participants mutually 

understood the importance of a coalition for a successful election bid. The parties later used key 

components from the training to decide to officially coalesce before the July election. On April 

16-17, IRI trained 23 members of a newly formed coalition, marking IRI’s first interaction with 

the alliance. The training concluded with the participants creating a 2-month campaign plan that 

detailed all activities up to and including Election Day. On May 26-27, IRI held database 

training for 15 individuals that represent the several Iraqi political parties. Participants learned to 

create, maintain and effectively manage a political party database using Microsoft Office Excel. 

On June 16-18, the IRI Media Center staff trained 17 members of a political party’s media team. 

The training comprised three separate sessions that included graphic design, editing and camera 

operations. IRI’s public opinion research program focused on recruiting and developing data 

collection and independent verification teams in various governorates. IRI has established these 

functions in Baghdad, Basra, Ninewa, Dahuk, Erbil, and Sulaymaniyah. 

Figure 2 is an IRI training activity, Figure 3 is the IRI Media Center in Erbil. 
29 

Figure 2—IRI Conducting a Training Session in Erbil 

Source: SIGIR 11/2009 

Figure 3—IRI Media Center Control Panel. 

Source: SIGIR 11/2009 
30 

NDI’s Advisors Assist the Iraq Council of Representatives 

NDI submitted seven quarterly progress reports for grant S-LMAQM-08-GR-210 covering the 

period October 1, 2007, through June 30, 2009. NDI’s progress reports identify the following 

objectives: 

• Objective 1: Strengthen democratic political institutions to facilitate effective pluralist 

governance; 

• Objective 2: Provide neutral space for political opponents to engage in inclusive 

dialogue and decision-making; 

• Objective 3: Promote increased participation of youth in political processes; 

• Objective 4: Promote the increased participation of women in political processes; 

• Objective 5: Support the monitoring of elections and strengthen party organizational 

skills. 

The following provides examples of the activity NDI reported in its progress report for the 

quarter ending June 30, 2009. 

Objective 1: Strengthen democratic political institutions to facilitate effective pluralist 

governance. 

From April 25 to 26, NDI Governance Program advisors met with 13 members of the Iraq 

Council of Representatives Committee on Education and Higher Education to revisit the mission 

and objectives the committee identified in its initial consultation with NDI in April 2008, 

identify current priorities, assist with the development of a communications plan; and facilitate 

outreach to other members of the Council of Representatives and the public. Committee 

members identified the following issues as priorities for the remainder of their term in office: (1) 

ensuring that 2010 budget allocations prioritize education on the Iraqi agenda; (2) focusing 

government attention on the issue of “brain drain” and proposing ways to address the problem; 

and (3) increasing the likelihood that university graduates are able to find employment. 

From May 8 to 10, NDI Governance Program advisors held an initial consultative session with 

10 members of the Council of Representatives Committee on Labor and Services. The purpose 

of the session was to gather information regarding the Committee’s structure, challenges, and 

priorities to assist it in developing an action plan for the remaining period of its current term. In 

the consultative session, committee members identified legislative, oversight, and 

communications challenges; respective objectives for each category; and a plan of action further 

each objective in the remainder of the term. 

Objective 2: Provide a neutral space for political opponents to engage in inclusive dialogue 

and decision-making. 

NDI did not report any activity under objective 2 for the quarter ending June 30, 2009. In the 

preceding quarter, NDI reported the parliamentary members of the Finance Committee engaged 

with the Council of Representatives Research Directorate to discuss and respond to the need for 

increased communication and information-sharing in a collaborative manner. 
31 

Objective 3: Promote increased participation of youth in political processes. 

NDI’s Civil Society Strengthening Program hosted four regional groups of Youth Empowerment 

Program participants for its new series on advocacy. The objectives of the training series are to 

(1) develop youth activists’ basic understanding of advocacy (2) enhance their skills to work 

with governments to implement advocacy objectives; (3) build their experience in creating 

advocacy strategies and action plans; and (4) increase their knowledge of best practices in 

advocacy, including comparative perspectives of strategies used in other countries. 

The youth activists’ discussion of advocacy was supplemented with information on the various 

types of advocacy, including lobbying, accountability, justice, and public education; best 

practices, including situations in which advocacy is most and least effective; and documentary 

programs demonstrating examples of advocacy in the United States and Kosovo. 

Objective 4: Promote the increased participation of women in political processes. 

NDI’s Women’s Political Participation Program developed the Political Academy for Female 

Party Activists. This five-module capacity-building program comprises of targeted skillsbuilding sessions on: membership recruitment and training of trainers; strategic planning and 

leadership building; field office organization and communication; media and public relations; 

and lobbying and advocacy campaign development. From May 20 to June 3, NDI advisors 

conducted module 1 of the Political Academy for female party activists through four mixed-party 

sessions for 236 activists from 11 political parties. 

From July 7 to 11, NDI advisors led a study mission to Amman, Jordan for a group of women 

participating in the Women’s Empowerment Program, a five-module capacity-building program 

that aims to empower female civic activists to play a more prominent role in non-government 

organizations and Iraqi public life. The study mission to Jordan aimed to facilitate information 

exchange and relationship-building between Iraqi activists and Jordanian female leaders working 

in various fields. The delegation met with women’s right advocates, lawyers, government 

advisors, and a female senator to discuss the advancement of women’s rights. Discussions 

focused on recent advances in the criminalization of honor killings and legislation to protect 

women from domestic violence. 

Objective 5: Support the monitoring of elections and strengthen party organizational skills. 

From June 29 to July 7, NDI Political Party Development Program advisors led a delegation of 

campaign committee members from nine Iraqi political parties to Bulgaria to complement the 

electoral support program implemented under DRL grant S-LMAQM-08-GR-602. The study 

mission aimed to expose campaign staff to an alternative electoral process to prepare them for 

their own political parties’ mobilization and recruitment for the July 2009 Kurdish regional 

elections and January 2010 national elections. Planned activities included: 

• a briefing on the Bulgarian political system and electoral process; 

• a visit to the Central Electoral Commission in Bulgaria; 

• analysis of televised political debates; 

• attendance at public campaign rallies and debates; and 

• observation of election day activities in Sofia and neighboring towns. 
32 

Figures 4 and 5 display examples of NDI activities. 

Figure 4—Political Party Members Select Issues for Provincial Council Campaign 

in Erbil. 

Source: NDI,7/2008. 

Figure 5—Civil Society Organizations Members at Training facilities in Erbil. 

Source: NDI, 1/2009
33 

Appendix D—Acronyms 

Acronym Description 

DoS United States Department of State 

DRL Bureau of Democracy, Human Rights, and Labor 

GOR grant officer representative 

IRI International Republican Institute 

NDI National Democratic Institute 

OECD Organization for Economic Co-operation and Development 

PARIS21 Partnership for Statistics for Development in the 21st Century 

SIGIR Special Inspector General for Iraq Reconstruction 

USAID United States Agency for International Development 
34 

Appendix E—Audit Team Members 

This report was prepared and the audit conducted under the direction of David R. Warren, 

Assistant Inspector General for Audits, Office of the Special Inspector General for Iraq 

Reconstruction. 

The staff members who conducted the audit and contributed to the report include: 

Bill Bedwell 

Walter Franzen 

Randy Gentry 

Art Granger 

Joan Hlinka 

Whitney Miller 

Nancee K. Needham 

William Shimp 

Robert Whitely 
35 

Appendix F—Department of State – Bureau of 

Democracy, Human Rights, and Labor Comments 
36 

 
37 

Appendix G—SIGIR Mission and Contact Information 

SIGIR’s Mission Regarding the U.S. reconstruction plans, programs, and 

operations in Iraq, the Special Inspector General for Iraq 

Reconstruction provides independent and objective: 

• oversight and review through comprehensive audits, 

inspections, and investigations 

• advice and recommendations on policies to promote 

economy, efficiency, and effectiveness 

• deterrence of malfeasance through the prevention and 

detection of fraud, waste, and abuse 

• information and analysis to the Secretary of State, the 

Secretary of Defense, the Congress, and the American 

people through Quarterly Reports 

Obtaining Copies of SIGIR 

Reports and Testimonies 

To obtain copies of SIGIR documents at no cost, go to 

SIGIR’s Web site (www.sigir.mil). 

To Report Fraud, Waste, and 

Abuse in Iraq Relief and 

Reconstruction Programs 

Help prevent fraud, waste, and abuse by reporting 

suspicious or illegal activities to the SIGIR Hotline: 

• Web: www.sigir.mil/submit_fraud.html 

• Phone: 703-602-4063 

• Toll Free: 866-301-2003 

Congressional Affairs Hillel Weinberg 

Assistant Inspector General for Congressional 

 Affairs 

Mail: Office of the Special Inspector General 

 for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-428-1059 

E-mail: hillel.weinberg@sigir.mil 

Public Affairs Danny Kopp 

Office of Public Affairs 

Mail: Office of the Special Inspector General 

 for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-428-1217 

Fax: 703-428-0818 

E-mail: PublicAffairs@sigir.mil